EPR compliance feels abstract until someone sends you a fine notice. Or until Amazon suspends your seller account. Or until a German customs authority blocks a shipment.
These aren't hypothetical. Here's exactly what happens when brands miss EPR obligations — by country — and why the risk is increasing in 2026.
Germany: the strictest enforcer in the EU
Germany has the most active EPR enforcement in the EU, run by the ZSVR (Zentrale Stelle Verpackungsregister).
What they can do:
Sales ban: Brands selling into Germany without LUCID registration can be issued a formal ban on placing packaging on the German market. This is not a fine — it's an order to stop selling, effective immediately.
Fines: The German Packaging Act (VerpackG) sets fines of up to €200,000 per violation. In practice, most first-time violations result in lower fines (€1,000–€20,000 range), but repeat violations or high-volume non-compliance attract the upper end.
Public listing: Non-compliant brands are publicly listed in the LUCID register as non-compliant. This is visible to anyone who checks, including competitors who may report you.
Competitor complaints (Abmahnungen): Germany has an active system of competitor warnings. A rival brand or association can file a formal complaint against a non-registered seller, triggering legal proceedings and fee demands that can reach tens of thousands of euros.
Retroactive fee demands: If you're found to have been selling without registration, the ZSVR can demand retroactive EPR fees for all past periods of non-compliance — potentially going back years.
Amazon specifically: Amazon.de requires LUCID registration numbers from all sellers. Brands without a LUCID number are suspended from listing. Amazon actively purges non-compliant sellers and shares enforcement data with the ZSVR.
France: audit-driven enforcement
France's enforcement is less automated than Germany's but increasingly active.
What they can do:
Fines: The French Environment Code (Code de l'environnement) sets fines of up to €7,500 per offence for failure to register or pay EPR contributions. For large-scale non-compliance, additional criminal liability can attach to company directors.
Administrative orders: ADEME (the French environmental agency) and prefectural authorities can issue formal compliance orders requiring registration within a set period.
Citeo audit: Citeo conducts its own audits of producer data. If they identify discrepancies between reported volumes and actual market data, they can issue revised invoices with retroactive adjustments.
Retroactive fees: Like Germany, France can demand past EPR fees from the date obligations were first triggered — not just from the date you registered.
From January 2026: Citeo Pro covers B2B packaging. Brands that have been ignoring the B2B side of their French EPR obligations will find themselves in scope and facing retroactive demands if they don't get ahead of this.
Italy: rising enforcement
Italy historically had lighter enforcement against small foreign brands, but this is changing.
What they can do:
Fines under Legislative Decree 116/2020: Up to €46,500 for failure to participate in a CONAI scheme. For significant non-compliance, fines can be higher.
CONAI investigation: CONAI can investigate packaging volumes placed on the Italian market and issue fee demands, including interest, for unpaid contributions.
Customs intervention: For physical goods imported into Italy, customs authorities can flag non-compliant producers, leading to delays and additional inspections.
Italy's threshold of zero (no de minimis exemption) means every brand selling into Italy has exposure, even small ones.
Spain: marketplace-led enforcement
Spain's enforcement has historically been led more by marketplaces than by regulators.
What they can do:
Ecoembes reporting: Ecoembes shares producer compliance data with MITERD (the Spanish Ministry for Ecological Transition). Non-compliant producers are identifiable.
Fines: Spain's Waste Law (Ley de Residuos) sets fines ranging from €300 (minor violations) to €200,000+ (serious violations).
Belgium has traditionally been more lenient than Germany for small foreign brands. But enforcement has tightened since 2024.
What they can do:
Fostplus retroactive invoicing: If you've been selling to Belgian consumers without Fostplus registration, Fostplus can issue invoices covering all historical periods. These carry standard interest charges.
Regional environmental authority fines: The three Belgian regional environmental authorities (Brussels, Wallonia, Flanders) each have enforcement powers and can fine non-compliant producers. Fines range from several thousand euros to €100,000+.
Netherlands: declaration-based risk
Dutch enforcement against small foreign brands has been light, but the landscape is changing.
What they can do:
Verpact investigation: Brands that don't file even the lightweight below-threshold declaration are increasingly flagged.
Retroactive participation fees: If found to be above 50,000 kg threshold without having joined the collective scheme, Verpact can demand fees for all non-compliant periods plus interest.
Austria: ARA audits
ARA conducts periodic audits of brands selling into Austria.
What they can do:
Retroactive fees + interest: Non-registered brands can be billed for all historical EPR fees owed, with compound interest.
Trade authority reporting: ARA can report persistent non-compliance to Austrian trade authorities, leading to broader regulatory consequences.
The marketplace factor: your biggest immediate risk
For most DTC brands, the biggest short-term risk isn't a regulator — it's your marketplace.
Amazon, Zalando, Otto, and other major EU platforms now actively enforce EPR compliance as a condition of selling. They ask for:
LUCID registration number (Germany)
Citeo contributor number (France)
ARA contract number (Austria)
Equivalent documentation in other markets
A missing compliance number triggers account suspension. That's immediate revenue loss, not a fine you have 30 days to pay.